Announcements, For NCA Candidates, Information, Latest News, NCA

This is the Success Bundle for NCA Foundations of Canadian Law Exams

Most NCA Candidates regard NCA Foundations as tough.

But this Study Material will help you.

The Bundle contains the following

  • Notes on Foundations of Canadian Law that is updated to the current NCA Syllabus. (The notes also contain abridged versions of all the articles in the current syllabus)
  • Summaries of principles in Foundations and summaries of facts and ratios of all cases in the current NCA Foundations syllabus. (It also contains summaries of each Article in the syllabus, NOT EXCEEDING ONE PAGE EACH).
  • Tips on How to Answer NCA Foundations Exam Questions.
  • (10) samples of Fact-based and Essay-type Questions & Answers on very important topics in the current NCA Foundations Syllabus. (Samples show how to incorporate the Articles in your exam answers).
  • (10) samples of Multiple-choice Questions & Answers.
  • (5) samples of Short-Answer Questions.

 All these materials available in one Bundle, to help you pass.

The Bundle Package is in PDF Format and can be downloaded instantly from anywhere in the world, at an affordable price you can never believe.

To purchase online and download instantly or to see the sample, please visit:



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Announcements, For NCA Candidates, Information, Latest News, NCA

This Bundle Package will help you Pass Your NCA Constitutional Law Exam this July

Bundle Package on Canadian Constitutional Law for NCA Exam in July 2023.

  • Are you writing the next NCA Constitutional Law exam?

  • Do you need study materials that is not only helpful and easy to understand but equally affordable?

  • Do you need an all-in-one study material that contains everything you need to pass your NCA Constitutional Law exam?

At, we have produced a Bundle Package on constitutional Law for the benefit of NCA candidates. This Bundle Package contains everything you need to pass, and this includes:

  • Notes on Canadian Constitutional Law updated to the most current NCA Syllabus.

  • Tips on How to Answer NCA Constitutional Law Exam Questions.

  • Summaries of facts and ratios of all cases in the current NCA syllabus as well as summaries of all the principles of Canadian Constitutional Law.

  • (10) Samples of Fact-based Questions & Answers on very important topics in the NCA Constitutional Law Syllabus.

  • (15) Samples of Multiple-choice Questions & Answers.

  • (10) Samples of Short-Answer Questions.

Numerous NCA candidates have reported that these materials have helped them pass their NCA Constitutional Law exam. You can’t be an exception.

These materials are all in PDF format and you can simply purchase on our website and download instantly to your device.

To purchase and download, please visit this page:

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Announcements, For NCA Candidates, Information, NCA

Congratulations to All Users of our Study Materials Who Passed

As NCA releases another batch of results this January, we have received numerous feedback from many NCA Candidates who said they passed their exams using our study materials. Many have confirmed that our study materials on Foundations of Canadian Law, Canadian Constitutional Law, and Canadian Professional responsibility helped them pass. We are indeed happy to be partners in your success stories.

This kind of feedback is very heartwarming and gives us the energy to strive to do more in ensuring the success of users of all our study materials.

Warm congratulations to you all.



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For NCA Candidates, Information, NCA

An Opinion on the impact of the Supreme Court of Canada’s decision in R. v. Brown

I’ve received several inquiries as to the effect of the recent decision of the Supreme Court of Canada (SCC) in R. v. Brown on the defence of extreme intoxication akin to automatism. Many sought to know if the decision meant that the defence of extreme intoxication remains valid or not in view of s. 33.1 of the Criminal Code, and to what extent intoxication would be recognized as a defence to a crime of general intent. Others have sought my opinion on the validity of the amendment made to section 33.1 by Parliament immediately after the decision in Brown.

Let me seek to provide a little explanation here, and in doing so, I wish to employ the simplest of languages to enable you better understand. To aid you in a better appreciation of the principles involved, I will start by providing some historical background to the defence of extreme intoxication. But before then, please take note of the difference between offences of general intent and those of specific intent, as we shall continuously make use of this term in this piece. In R. v. Daley, (2007) 3 S.C.R. 523, the SCC encapsulated the distinction in these words: “Specific intent offences require the mind to focus on an objective further to the immediate one at hand, while general intent offences require only a conscious doing of the prohibited act”. See also R. v. Bernand (1988) 2 S.C.R. 833. Therefore, a crime of general intent is that where the offender does not need to form the specific intent to commit the crime. The mens rea can be implied from the commission of the act. An example of general intent offence is assault. On the other hand, crimes of specific intent are those which require that the offender must have formed the specific mens rea to commit the act, e.g., murder. One of the legal effects of this distinction is that where the court did not find the specific intent to convict for, e.g., murder, the accused can be found guilty of e.g., manslaughter, a general intent offence.

Traditionally, under common law, the rule is that intoxication is not recognised as a defence to a criminal charge. This rule persisted also in Canada and was reiterated by the SCC in R. v. Leary (1978) 1 S.C.R. 29 where the Court held that intoxication akin to insanity could not negate mens rea for “general intent” crimes such as sexual assault. So, notwithstanding that an accused was found to be sufficiently intoxicated at the time of the offence, so much that he was unable to form the “minimal mental element” required for a general intent offence, he may still be held liable as the act of inducing intoxication can be substituted for the requirement of mens rea. This later became known as the “Leary rule”, and its effect was to make the mental element of inducing oneself to intoxication a substitute for the mental element required of the crime committed while in that state. Therefore, intoxication was not available as a defence to a criminal offence of general intent. This was the rule up until 1994.

In 1994, the constitutionality of the Leary Rule was challenged in R. v. Daviault. In that case, D was charged with sexually molesting a semi-paralysed woman in a wheelchair. His defence was that he had no recollection of the events because he had taken a substantial amount of alcohol. He challenged the Leary rule on the ground that he could not have formed the mens rea required for the offence of sexual assault as a result of his state at the material time.  He argued that he had blacked out and was in a state akin to automatism provoked by the alcohol. An expert witness also testified that having taken the amount of alcohol D was said to have taken on the day of the incident, there was little chance that he could have functioned normally or was even aware of his actions.

Based on this evidence, the trial judge acquitted D, holding that he was unable to form a general intent to commit the crime of sexual assault. This decision was upturned by the Quebec Court of Appeal which held that intoxication to the point of automatism cannot negate the mens rea requirement for a general intent offence. But at the SCC, one of the issues was whether “a state of drunkenness which is so extreme that an accused is in a condition that closely resembles automatism or a disease of the mind as defined in s. 16 of the Criminal Code constitute a basis for defending a crime which requires not a specific but only a general intent?”. Ordering a new trial, the Court held that denying an accused the defence of intoxication akin to automatism for a general intent offence violated ss. 7 and 11(d) of the Charter. The SCC thus recognised that while, as a general rule, intoxication is not a defence to general intent offences, an exception can be recognised where the intoxication is so extreme that it is akin to automatism or insanity. (Please note, however, that the Court did not overturn the Leary rule with regards to typical forms of intoxication).

In reaction to this judgement, Parliament in 1995 effected an amendment to the Criminal Code by inserting s. 33.1 to the effect that the defence of extreme intoxication is not available when the intoxication is self-induced and where the accused has departed markedly from the standard of care generally recognised in Canadian society. Subsection (2) provided that a person departs markedly from this standard of care and is criminally at fault if, while in the state of self-induced intoxication that renders him unaware or incapable of controlling his conduct, voluntarily or involuntarily interferes or threatens to interfere with the bodily integrity of another person.  So, by virtue of this provision, when an accused was charged with an offence involving violation of bodily integrity, he was not allowed to raise the defence of extreme intoxication akin to automatism. This was the operating statutory provision from 1995 until it was again constitutionally challenged in Brown.

In R. v. Brown 2022 SCC 18, the accused was charged with aggravated assault of a woman. His defence was that he had consumed a substantial amount of alcohol and “Magic Mushrooms”, an illicit drug that contain psilocybin and provokes hallucinations and deliriums when ingested, and thus lost touch with reality. Brown contended that he lacked the required mens rea for the alleged crime because he was in a state of automatism at the point in time. He called expert evidence who also confirmed that ingesting the magic mushrooms in combination with alcohol could have provoked the delirium suffered by Brown.

In response to this defence, the Crown invoked s. 33.1 of the Criminal Code that Brown could not use self-induced intoxication as an excuse to say he lacked the general intent or the voluntariness required to commit the offence.  Brown then mounted a challenge against the constitutionality of s. 33.1, contending that the provision violated his right to personal liberty, presumption of innocence and right to full answer and defence in ss. 7 and 11(d) of the Charter respectively. The trial court agreed with him and struck down s. 33.1 of the Criminal Code as unconstitutional, acquitting Brown of the charges. The Alberta Court of Appeal reversed this decision and set aside Brown’s acquittal.

Upon a further appeal by Brown to the SCC, the Crown argued that s. 33.1 should be read purposefully to mean that the act of voluntarily intoxicating oneself to an extreme level is a marked departure from the standards of reasonable care generally recognised in Canadian society and that the provision should be declared valid. But the Supreme Court in a unanimous judgment delivered in May 2022 agreed with the trial judge that s. 33.1 was unconstitutional for the following reasons:

  • The principle of fundamental justice under s. 7 of the Charter is well established that criminal offences require a minimum fault requirement of at least negligence. However, in s. 33.1, Parliament merely substituted the intent to get intoxicated with the mens rea for the general intent offences against bodily integrity. This is a violation of s. 7 of the Charter which requires that all criminal offences must have a minimum mens rea.


  • 33.1 also offends s. 11(d) of the Charter which guarantees the presumption of innocence and which requires the Crown to establish all essential elements of an offence. On the contrary, s. 33.1 declares that proof of the intention to consume the intoxicant could be substituted for the intention to commit the predicate offence. Hence, the implication of the provision was that proof that the accused intended to become intoxicated satisfied the proof of one of the essential elements of an offence against the bodily integrity of another person. The Court noted that this is too broad because the intention to become intoxicated to any degree under the provision suffices. It does not matter that the person taking the intoxicant did not foresee their loss of awareness or control. The provision does not also take into account the licit or illicit nature of the intoxicant or its known properties in that it captures those who recklessly invite their own loss of control, as well as those who did so due to unexpected involuntariness, e.g., as a result of unexpected reaction to a prescribed pain medication.


  • The above notwithstanding, an accused presenting the defence of extreme intoxication akin to automatism is under an evidentiary burden to satisfy the trial judge that the intoxication was so extreme that it is akin to automatism. The defence is only permitted in rare circumstances, and as observed by Kasirer J. who delivered the unanimous judgment,

.… it is notable that extreme intoxication akin to automatism is an exigent defence requiring the accused to show that their consciousness was so impaired as to deprive them of all willed control over their actions. This is not the same as simply waking up with no memory of committing a crime. A failure to remember does not prove that an individual was acting involuntarily. Nor is it the same as suffering a psychotic episode where physical voluntariness remains intact. (At para 50)

The evidentiary burden includes the calling of an expert witness (psychiatric, pharmacologist, toxicologist, etc.) who must confirm that the nature and properties of the substance can and did indeed provoke the loss of control in this accused person.

  • However, the declaration of unconstitutionality did not affect the common law rule that intoxication short of automatism is not a defence to violent crimes of general intent such as assault or sexual assault. Per Kasirer J., “I specifically leave intact the common law rule that drunkenness, absent clear scientific evidence of automatism, is not a defence to general intent crimes, including crimes of violence such as sexual assault.”
  • The Court recognized the pressing and substantial social purpose behind Parliament’s desire to protect victims of extreme intoxicated violence, particularly women and children who are more vulnerable to intoxicated sexual and domestic violence, and that it is not impermissible for Parliament to enact legislation to hold extremely intoxicated person accountable for violent crimes. However, there are other constitutional and legitimate means to do this.

In reaction to this new judgment, Parliament again amended the Criminal Code in June 2022 to accommodate SCC’s judicial reasoning. The new s. 33.1 in subsection (1) now includes the fault element by requiring that all the elements of the offence must be present, and that before they were in a state of extreme intoxication, the accused departed markedly from the standard of care expected of a reasonable person in the circumstances with respect to the consumption of intoxicating substances. The new provision has now removed involuntariness in the conduct of the accused, and perhaps, has given effect to the Crown’s interpretation of the erstwhile s. 33.1 that extreme consumption of intoxicating substances is of itself a marked departure from the standard of care expected of a reasonable person.

S. 33.1(2) also gives the court the role of determining whether the person departed markedly from the standard of care, listing the criteria to be considered in making this determination as whether he could have reasonably foreseen the risk that his consumption of the intoxicating substance could cause extreme intoxication which could lead him to harm another person, and whether he had taken any step to avoid this. Whether this provision will stand the test of time is also a question of time.


So, as NCA candidate writing the Criminal Law exam, you need to carefully understand the facts of your exam question. You are advised to confirm that the facts relate to extreme intoxication akin to automatism, because as the SCC held in Brown above, the common law rule still stands that mere intoxication is not a defence to crimes of general intent.

Secondly, check the facts of your exam question to be sure that the accused person has complied with the evidentiary burden of satisfying the judge as to the nature and quantity of intoxicating substance taken to enable the judge determine if it is sufficient to provoke an extreme state akin to automatism. So also, the defence must call confirming scientific evidence to support the claim that the substance has the effect of, and did provoke loss of control in the particular accused. A general assumption or theory will not suffice.

Thirdly, it is true that the SCC invalidated the erstwhile s. 33.1 of the Criminal Code. However, the amended s. 33.1 remains valid and in force, until otherwise struck. So, while answering your exam question, please relate it to the provisions of the new s. 33.1, not the old one.

All the best.


Manuel Akinshola
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Announcements, BAR Candidates, Information, Latest News

Our website now fully ready for you.

I’m glad to notify you that the upgrading of our website is now fully completed.


  1. we have made it easier for our users to be able to go to the section that is specific to their need. Basically, we have 3 sections: new applicants, NCA candidates, and Bar candidates. So, users can now go straight to that section that contains all the information, products and services that are relevant to them.
  1. For new applicants, you can easily make use of our eligibility portal to determine if you are eligible for NCA qualification. And then you are taught as to the requirements to ensure a successful application.
  1. For NCA candidates, it is now a lot easier for you to obtain all the materials that you need in one place. We have now compartmentalize all materials per subject. So, under each subject, it will be easier for you to see all available study materials, add them to wishlist or cart as you go along, and checkout at the same time. Easy navigation is the watchword. You can now also easily navigate to our online practice exam portals. Please note though that not all study materials for all the subjects are presently available. But we will keep updating our webpages as these materials become available.
  1. For bar candidates, we have created a special and content-specific website, dedicated only to bar exams and resources. It is; it is more resourceful, more engaging, more interactive and more functional. So, all bar candidates will henceforth be automatically redirected to this webpage. But, in the meantime, those who have pending subscriptions on still have the opportunity to exhaust them.

In all, the objective of these new changes are easy navigation and usability. And we hope the end will ultimately justify the means.

Thanks for your continued patronage.


Manuel Akinshola

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Announcements, Information, Latest News

Hurray… our site is upgrading

I announce to you the heartwarming news that our website is upgrading.

We are making the website more robust and resourceful, to make it easier for all users to quickly locate the materials they need.

The upgrading is already in progress and will be completed in the next few days.

In the interim, you may find some pages unresponsive. Never worry, we are still working on them. Everything should be okay in a couple of days by the time you check back.

All these are for your convenience and ease of navigation.

Thanks for staying with us through the years.

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Announcements, BAR Candidates, For Bar Candidates, Information, Latest News

HURRAY! It’s ONE YEAR ANNIVERSARY of our Bar Practice Exams!!

Come celebrate with us!.

Today, one year ago, our LSO Bar Practice Exam portal was officially launched.

It is our birthday and we are extremely happy to celebrate it.


And since we launched, we have grown from strength to strength.

Many candidates who used our Bar Practice Exams portal confirmed that it tremendously helped them in passing their Bar exams. And they keep coming back after each stage. This is the source of our strength: that we are getting right.

And, we saw into the future!

From the beginning, we had already programmed our exam portal based totally on the online format. We configured in such a way that candidates can take the exam and get their raw results instantly. And they can also revise the exam taken to know which answer was right or wrong.

And then Covid-19 came, and the Law Society of Ontario (LSO) was forced to also officially adopt the online exam format in July 2020!

LSO also changed the exam questions to 160 from 120 and changed the exam duration from 3 hours to 4. But with all these changes, it was so easy for us to seamlessly update our exam portal to align with LSO’s new format. We were thus the first provider to adopt the 160 multiple-choice questions and the 4-hour exam period.

Our practice exam questions were also updated to include every necessary questions that candidates may come across in the real Bar exams. Now, our portal is fully updated to make it easy for bar candidates to practice and get familiar with the real exam in advance.

365 days later, we are so elated because the feedback received from candidates who subscribed to our Bar Practice Exams was so encouraging. Many of them praised our Bar Practice Exams to high heavens. A particular candidate said he had attempted the Barrister Licensing Examination twice but failed. And he was scared that it would be the end if he failed the 3rd time. He subscribed to our Bar Practice Exams, and months later, came back reporting that he passed, thanks to our practice exams which prepared him well. It was such a joyous and emotional moment for us.

Today, we are so glad that we have many users on our platform. We have grown tremendously in our user base and many more candidates are joining us by the day.

We will not rest on our oars. For the next 365 days, we hope to keep improving on our Bar Practice Exams. The sole aim of our practice exams is to help Ontario Bar candidates pass their exams. And we shall continue to pursue this mission by all legitimate means.


What’s in store for the next one year?

In the next one year, there shall be some radical changes to our exam portal. No fear! All is geared towards assisting the candidates. We assure our users that they will enjoy these changes more.

And for all our loyal users who still have one or two bar exams to write, we are giving you our anniversary gifts, in the form of a massive discount. This is to appreciate you for your support these past 365 days. Please check here for details of this discount.



To all of our users, present and prospective, we say THANK YOU for your patronage, commendations, advice, observations and feedback. They were a treasure. and You made our day.

Happy Celebrations….!!!

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